IN THE UNITED STATES DISTRICT COURT 

 FOR THE EASTERN DISTRICT OF PENNSYLVANIA

GRACE LAWRENCE 

Plaintiff, 

v. 

TRANS UNION LLC 

CITY OF PHILADELPHIA 

Defendant. 

C.A. NO: 02-CV-4440 

JOINT MOTION FOR EXTENSION OF TIME

Trans Union LLC (“Trans Union”) and Plaintiff Grace Lawrence (collectively referred to as the 

“Parties”), by and through their undersigned attorneys, jointly move that the trail of this case be 

adjourned from February 23, 2004 and rescheduled on or after March 15, 2004, subject to the conflicts 

set forth below: 

1. Plaintiff commenced this action alleging that Defendant Trans Union violated the Fair 

Credit Reporting Act, 15 U.S.C. §§ 1681 et seq. (the “FCRA”) because it reported certain allegedly 

inaccurate credit information relating to Plaintiff. 

2. On December 11, 2003, the Court denied in part and granted in part Trans Union’s 

motion for summary judgment. Trans Union’s motion for partial reconsideration is pending. On 

January 9, 2004, the Court scheduled the trial in this action for February 23, 2004 and a final 

pretrial for February 18, 2004. 

3. Counsel for Trans Union have pre-scheduled federal jury trials set for February 23, 

2004: Luckman – Ahern v. Trans Union, (D.Ct. 3:01CV 2313 (DJS), Squatrito, J.; counsel for 

Case 2:02-cv-04440-AB Document 46 Filed 01/23/2004 Page 1 of 3
both Parties are also scheduled to try Evantash v. Trans Union and GE Capital, (E.D.Pa. NO. 02-

1188, Davis, J) on March 9, 2004; and counsel for Plaintiff have a trial set in Harvey v. Equifax, 

(E.D.Pa. NO. 03-3143, Fullam, J) on March 28, 2004 . 

4. Counsel for Trans Union, (Luckman) also has prepaid vacation plans (nonrefundable flights and hotels at Disneyworld) from March 24 through April 1, 2004. 

5. Further, the Parties respectfully submit that the pretrial orders, filed in June 2003, 

require modification in light of the Court’s Order on Summary Judgment and, potentially, the 

disposition of Trans Union’s Motion for Reconsideration. 

6. Accordingly, the Parties respectfully request that the January 8, 2004 Order be 

modified and extended as follows: 

(a) Trial on or after March 15, 2004 (subject to the above conflicts); 

(b) Parties’ modified pretrial memoranda, proposed points for charge, proposed jury 

verdict form, and proposed voir dire as well as all pre-trial motions, within ten (10) days of trial; 

(c) All trial exhibits, which are to be pre-marked, to be exchanged within five (5) days 

of trial; 

(d) Final pre-trial conference to be held in chambers five (5) prior to trial, 

7. This extension of time is sought in the interests of justice and is made in good 

faith and not to unnecessarily delay the trial of this action. 

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WHEREFORE, Defendant Trans Union LLC and Plaintiff, Grace Lawrence, jointly, 

respectfully request that this Court grant an extension of time. 

Respectfully Submitted this 23rd day of January , 2003 

___________________________________

MARK E. KOGAN 

BRUCE S. LUCKMAN 

TIMOTHY P. CREECH 

SATZBERG, TRICHON, 

 KOGAN & WERTHEIMER, P.C. 

1818 Market St., 30th Floor 

Philadelphia, PA 19103 

(215) 575-7600; Fax: (215) 575-7688 

Counsel for Defendant, 

Trans Union LLC 

John Soumilas By/S/TPC w/ express permission 

___________________________________

MARK D. MAILMAN 

JOHN SOUMILAS 

FRANCIS & MAILMAN, P.C. 

Land Title Building, 19th Floor 

Philadelphia, PA 19110 

(215) 735-8600; Fax: (215) 940-8000 

Counsel for Plaintiff 

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